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Anti-corruption policy


Our commitments


Our aim is to reiterate our commitment to comply with regulations that prevent and combat corruption, and expand compliance not only to all employees of all the companies belonging to the IN-VR, whether directly or indirectly managed by our Company but also to our business partners.

IN-VR rejects all forms of corruption and will apply a zero-tolerance approach in respect to any breach of this policy.

To prevent corruption, IN-VR will perform all its operations in accordance with the applicable laws in all areas of activity and in all the countries in which we operate, respecting their spirit and purpose. Accordingly, IN-VR will:

  • Not exert any influence on the will or objectiveness of persons in order to obtain a benefit or rewards through practices that are unethical or contrary to applicable laws.

  • Not give, promise or offer, directly or indirectly, anything of value to any person or entity in order to obtain undue benefits for the Company.

  • Not allow any facilitating payment.

  • Not finance or support directly or indirectly any political party or its representatives or candidates.

  • Not use donations to conceal undue payments.

  • Not request or unduly receive, directly or indirectly, commissions, payments or rewards from third parties as a result of investments, divestments, financing or expenditure made by the Company.

  • Pay special attention to those cases where there appears to be lack of integrity with any person or entity with whom we deal with, to ensure that IN-VR establishes business relationships only with qualified and reputable persons or entities.

  • Accurately record all financial transactions in the Company's books and records.

  • Promote internal training on preventing and combating corruption.
     

Employees that have evidence, questions or suspicions regarding any form of corruption must report immediately to their supervisor, Legal Services, or to the IN-VR Chief Compliance Officer. Employees and third-parties may also raise their questions or concerns through the IN-VR Ethics and Compliance Channel.
 

IN-VR will not tolerate any retaliation against anyone who in good faith asks questions or makes a report of actions that may be inconsistent with this policy.


Employees who act contrary to this policy are subject to discipline, which could include termination as well as possible legal proceedings and penalties. Legal consequences imposed under anti-corruption laws can also have a serious impact for both employees and IN-VR.


IN-VR reserves the right to adopt the measures it considers appropriate against any business partners who do not comply with this policy.

All IN-VR employees are responsible for complying with this policy.

This policy was approved by the Chief Executive Officers of IN-VR, Limited. on May 20th, 2019.

The full anti-corruption and anti-bribery policy can be viewed here.

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